ESMA Guidelines on stress test scenarios under Article 28 of the Money Market Fund Regulation โ Update 2025 (ESMA50-481369926-30585)
Circular CSSF 26/911 informs Luxembourg money market fund (MMF) managers that the CSSF is integrating ESMAโs 2025 update of the stress test scenarios under Article 28 of the Money Market Fund Regulation (MMFR), and that these new ESMA Guidelines now form part of the Luxembourg supervisory expectations. The circular repeals and replaces Circular CSSF 25/877 as of 26 May 2026 and requires MMFs and their managers to apply the 2025 stress test parameters for MMF reporting from the reporting date 30 June 2026 onwards, driving immediate model, data, and reporting changes.
What Changed
- - Circular CSSF 26/911 replaces Circular CSSF 25/877 and integrates ESMAโs 2025 Guidelines on stress test scenarios under Article 28 of Regulation (EU) 2017/1131 (MMFR), making the updated scenarios...
- The 2025 ESMA Guidelines (Ref. ESMA50-481369926-30585) update the common reference stress test parameters for MMFs, reflecting more recent market conditions and liquidity risk drivers than the 2024...
- The circular clarifies that MMFs and MMF managers must use the updated 2025 ESMA stress test scenarios when preparing the MMF reporting required under the MMFR and the related Commission Implementing...
- Circular CSSF 26/911 confirms that the 2025 Guidelines and their translations, published by ESMA on 26 March 2026, are now integrated into CSSF supervisory practice, following the ESMA process...
- The circular reiterates that MMFs and their managers must tailor the ESMA reference scenarios to the specificities of each MMF, adding additional risk factors or requirements where needed to ensure...
Suggested Considerations
- Identify all MMFs and MMF mandates in scope of Regulation (EU) 2017/1131 for which the CSSF is the competent authority and confirm that they are currently using the 2024 ESMA stress test framework under Circular CSSF 25/877.
- Obtain and review in detail the ESMA 2025 Guidelines on stress test scenarios (ESMA50-481369926-30585) and the annexed parameters as integrated by Circular CSSF 26/911, comparing them lineโbyโline to the 2024 version to map all methodological and parameter changes.
- Update the MMF stress testing policy and procedures to reference Circular CSSF 26/911 and the 2025 ESMA Guidelines, including explicit descriptions of the scenarios, calibration choices, modelling techniques, and governance for scenario approval.
- Recalibrate stress testing models and tools used for MMFs to reflect the 2025 common reference parameters, ensuring that interest rate shocks, credit spread moves, liquidity shocks, redemption scenarios, and concentration risks are aligned with the new ESMA specifications.
- Perform impact analyses on representative MMFs using both 2024 and 2025 parameters to quantify changes in stress outcomes, and prepare internal briefing materials for senior management and boards explaining the impacts on liquidity and risk profiles.
Key Dates
- ESMA publishes the English, French, and German translations of the 2025 Guidelines on stress test scenarios under Article 28 MMFR on its website, starting the twoโmonth period to application
- Circular CSSF 26/911 enters into force and Circular CSSF 25/877 is repealed and replaced, making the 2025 ESMA Guidelines the applicable stress testing framework in Luxembourg
- MMFs and MMF managers must apply the 2025 ESMA Guidelines for the preparation of the required MMF reporting as from the reporting date 30 June 2026 onwards, meaning that stress test calculations underlying this and subsequent reports must be based on the 2025 parameters
Compliance Impact
Nonโcompliance with Circular CSSF 26/911 and the integrated 2025 ESMA stress test Guidelines can lead to MMF reporting deficiencies, supervisory findings, and potential riskโmanagement remediation measures imposed by the CSSF, including expectations to strengthen liquidity and governance. Persistent or material breaches could contribute to more intrusive supervisory engagement, restrictions on MMF activities, or sanctions under the MMFR and Luxembourg supervisory framework.
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerBankHedge Fund
No description available.
All Firms
No description available.
All Firms
This report has been prepared by the SSM Network of Enforcement and Sanctions Experts to present comprehensive statistics on sanctioning activities carried out in 2025 by the ECB and the national competent authorities (NCAs) of European Union (EU) Member States participating in the Single Supervisory Mechanism (SSM) in relation to breaches of prudential requirements.
All Firms
No description available.
BankAsset ManagerWealth Manager
No description available.
BankWealth ManagerAll Firms
No description available.
BankAsset ManagerWealth Manager
ESMA Guidelines on Liquidity Management Tools (LMTs) of UCITS and open-ended AIFs (ESMA34-671404336-1364)
Circular CSSF 26/910 announces the CSSF's application of ESMA Guidelines on Liquidity Management Tools (LMTs) for UCITS and open-ended AIFs, establishing standards for selecting, calibrating, and using LMTs to manage liquidity risks and mitigate financial stability threats. This matters for Luxembourg investment fund managers (IFMs) as it enforces uniform EU-wide supervisory practices under UCITS Directive Article 18a(2) and AIFMD Articles 16(2b)/(2c), holding IFMs primarily accountable for liquidity risk oversight.
What Changed
- - Adoption of ESMA Guidelines: CSSF formally applies ESMA's guidelines (ESMA34-671404336-1364), focusing on LMT selection (e.g., redemption gates, suspension of redemptions/dealings, side pockets),...
- Calibration Requirements: IFMs must demonstrate fair and reasonable ADT calibration for normal and stressed conditions, including explicit transaction costs and, where appropriate, estimated implicit...
- LMT Recommendations: IFMs should select at least one quantitative-based LMT, one ADT, one for normal conditions, and one for stressed conditions; consider additional measures.
- Scope Expansion Recommendation: Open-ended SIFs (not under Part II of the 2010 Law) should consider the circular alongside Commission Delegated Regulation (EU) 2026/465.
Suggested Considerations
- Review and Update Policies: IFMs must select, calibrate, activate/deactivate LMTs per ESMA guidelines, documenting fair/reasonable ADT calibration (e.g., transaction costs, market impact analysis).
- Demonstrate Compliance: Be prepared to show regulators liquidity risk management, including at least one quantitative LMT, one ADT, and condition-specific tools; integrate with UCITS/AIFMD requirements.
- Risk Management Integration: Ensure primary responsibility for LMTs, with consistent supervisory application; open-ended SIFs to cross-reference with (EU) 2026/465.
- Supervisory Preparedness: Maintain records of previous transactions for market impact estimation and overall LMT rationale.
Key Dates
Publication and CSSF application date of ESMA Guidelines via Circular CSSF 26/910
Compliance Impact
Urgency: High โ Published today (15 April 2026), this imposes immediate supervisory expectations on liquidity risk management for Luxembourg's dominant fund sector, where non-compliance risks enforcement under UCITS/AIFMD. IFMs must promptly review LMT frameworks to avoid supervisory scrutiny, especially amid potential market stress.
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerHedge Fund
regarding the โLMT activationโ module in relation to additional liquidity management requirements for Luxembourg-domiciled UCITS, or where applicable their management company, and Luxembourg-authorised AIFMs that manage open-ended AIFs, introduced by the Law of 3 March 2026, transposing Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024
Asset ManagerBank
Situation as at 31 March 2026
BankAsset ManagerBroker Dealer
Situation as at 28 February 2026
BankAsset ManagerWealth Manager
Situation from March 2025 to March 2026
BankAsset ManagerBroker Dealer
Situation from March 2025 to March 2026
BankAsset ManagerBroker Dealer
Situation from March 2025 to March 2026
Asset ManagerBankBroker Dealer
relating to the issue of covered bonds
BankWealth ManagerAll Firms
on the operationalisation of European regulations in the area of financial services
BankAsset ManagerWealth Manager
on markets in financial instruments
BankAsset ManagerBroker Dealer
concerning the audit profession
BankWealth ManagerAsset Manager
on the failure of credit institutions and certain investment firms
BankWealth ManagerAsset Manager
relating to undertakings for collective investment
Asset ManagerWealth ManagerBank
transposing Directive 2004/25/EC of the European Parliament and of the Council of 21 April 2004 on takeover bids
BankBroker DealerAsset Manager
on institutions for occupational retirement provision in the form of SEPCAVs and ASSEPs
Asset ManagerBankInsurance
on the financial sector
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
Asset ManagerBankWealth Manager
Press release 26/08
Asset ManagerBankWealth Manager
No description available.
Asset ManagerWealth Manager
on the setting of the countercyclical buffer rate for the second quarter of 2026
Bank
Situation as at 28 February 2026
Asset ManagerWealth Manager
Situation as at 28 February 2026
BankAsset ManagerWealth Manager
Situation as at 28 February 2026
Asset ManagerWealth Manager
No description available.
Asset Manager
Survey on the amount of covered deposits held on 31 March 2026
Circular CSSF-CPDI 26/50 mandates a recurring annual survey on the amount of **covered deposits** held as of **31 March 2026** by specified Luxembourg credit institutions, to support the Fonds de garantie des dรฉpรดts Luxembourg (FGDL) in meeting Deposit Guarantee Scheme (DGS) requirements under the 2015 Law and DGSD. This matters for compliance as it ensures institutions contribute accurately to the FGDL's buffer (targeting 2% of covered deposits by 2026), with data also feeding into Single Resolution Board (SRB) calculations for resolution funding.
What Changed
This circular introduces no substantive changes to survey content, methodology, or reporting specifications compared to prior issuances (e.g., CSSF-CPDI 25/49 for 31 December 2025). Updates are limited to the reference date (31 March 2026) and associated deadlines, maintaining the risk-based ex-ante contribution method from Circular CSSF-CPDI 20/21 and quarterly reporting under CSSF-CPDI 17/07.
Suggested Considerations
- Compile data on covered deposits (eligible deposits up to โฌ100,000 per depositor, per Article 163 of 2015 Law), excluding items per Article 172 (e.g., financial institutions, life insurance).
- Report detailed breakdowns: total eligible/covered deposits, omnibus/fiduciary accounts (with beneficiary counts), natural vs. legal persons, branch-level data.
- Submit via specified format (per attached specs, unchanged from priors) to CPDI by deadline; quarterly data ongoing per CSSF-CPDI 17/07.
- Ensure alignment with FGDL contributions under CSSF-CPDI 25/48.
Key Dates
- Reference date for snapshot of covered deposits
(inferred from pattern in prior circulars like 25/49) - Likely submission deadline for survey data to CPDI (exact date in full PDF; aligns with one-month post-reference in predecessors)
Compliance Impact
Urgency: High โ Immediate action required today (publication date) to prepare for 31 March 2026 snapshot (just 5 days away), with submission likely due early May 2026. Non-compliance risks FGDL penalties, inaccurate contributions (impacting 0.8% extra buffer to 2% DGSD minimum), and SRB reporting failures under Regulation (EU) 2015/63; recurring nature demands robust quarterly data processes.
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
Bank
Amendment of Circular CSSF 18/703 on the introduction of a semi-annual reporting of borrower related residential real estate indicators
Circular CSSF 26/908 amends Circular CSSF 18/703 to update semi-annual reporting requirements for borrower-related residential real estate indicators, enhancing supervisory oversight of credit risk in Luxembourg's financial sector. Published today (25 March 2026), it matters for credit institutions as it refines data collection to better monitor real estate lending exposures amid potential market vulnerabilities.
What Changed
The circular introduces amendments to the original Circular CSSF 18/703 (itself amended by Circulars CSSF 20/737 and 21/772), focusing on semi-annual reporting of indicators tied to borrowers in residential real estate. Specific changes are not detailed in the provided summary or full content excerpt, but they likely involve refinements to reporting templates, data granularity, or submission processes to align with evolving EU prudential standards on real estate risk monitoring. The updated consolidated version of Circular CSSF 18/703 is now available as a 258.91Kb PDF.
Suggested Considerations
- Download and review the full Circular CSSF 26/908 (291.96Kb PDF) and the updated consolidated Circular CSSF 18/703 (258.91Kb PDF) from the CSSF website: https://www.cssf.lu/en/Document/circular-cssf-26-908/.
- Conduct a gap analysis of current reporting processes against the amended requirements for borrower-related residential real estate indicators.
- Update internal systems, data collection templates, and reporting workflows to ensure accurate semi-annual submissions to the CSSF.
- Train relevant compliance, risk, and finance teams on changes; document compliance confirmations for audit trails.
Key Dates
- Original issuance of Circular CSSF 18/703 introducing semi-annual reporting
- Publication date of Circular CSSF 26/908 (today)
Compliance Impact
Urgency: Medium - This is a targeted amendment to existing reporting obligations rather than a new regime, reducing immediate disruption, but non-compliance risks supervisory scrutiny, fines, or enhanced monitoring given CSSF's focus on real estate risk. It matters for maintaining accurate credit risk data, especially in a potentially volatile residential property market, supporting broader prudential stability.
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
Bank
Version of 9 March 2026
The CSSF Technical FAQ on Regulation No 20-08 provides implementation guidance on **loan-to-value (LTV) limits for residential real estate credit in Luxembourg**, establishing borrower-based macroprudential measures designed to limit leverage in the mortgage market. This guidance is critical for lenders operating in Luxembourg as it clarifies how to calculate own funds, determine LTV compliance, and apply temporary portfolio exemptions that have been extended through June 30, 2025.
What Changed
- The most recent update (March 9, 2026) to the Technical FAQ reflects the regulatory framework established by CSSF Regulation No 20-08 (as modified by Regulation No 24-10).
- First-time buyers: LTV limit of up to 100%
- Other buyers: LTV limit of 90%, implemented via portfolio allowance
Buy-to-Let Residential Loans:
- Standard LTV limit of 80%
- Temporary exemption (until June 30, 2025): Lenders may apply LTV ratios up to 95% for up to 10% of annual production
Other Residential Real Estate Loans:
Suggested Considerations
- *For all lenders:
- *Verify LTV compliance calculations for all new residential mortgage originations using the framework specified in the FAQ, ensuring own funds are calculated as actual equity contributions from borrowers
- *Implement dual LTV tracking for borrowers financing new property through sale of existing property, ensuring compliance with both interim and final LTV ratios
- *Document own funds sources carefully, particularly when cash collateral or sale proceeds are used, as these are only permitted for loans with initial LTV below 100%
- *Prepare for June 30, 2025 transition by:
Key Dates
- CSSF Regulation No 20-08 originally published
- Regulation and LTV limits became effective for residential real estate credit on Luxembourg territory
- CSSF Regulation No 24-04 introduced temporary adjustments to LTV limits
- CSSF Regulation No 24-10 extended temporary adjustments
- Most recent Technical FAQ version published (prior to March 9, 2026 update)
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
BankFintech
on the introduction of a semi-annual reporting of borrower-related residential real estate indicators
Circular CSSF 18/703 introduces semi-annual reporting requirements for Luxembourg-based lenders on borrower-related residential real estate (RRE) indicators to monitor macroprudential risks in the RRE lending market, in line with ESRB Recommendation 2016/14 (as amended). It matters for compliance because it mandates data collection via a dedicated CSSF template, with exclusions only for banks below EUR 10 million in outstanding RRE exposures, ensuring supervisory oversight of lending standards. The circular has been iteratively amended (CSSF 20/737, 21/772, 26/908), with the latest update on 25 March 2026 refining reporting processes.
What Changed
- - Original Scope (CSSF 18/703, 17 Dec 2018): Requires semi-annual reporting of RRE indicators for loans secured by Luxembourg residential real estate (existing dwellings, under construction,...
- Amendment CSSF 20/737 (19 Feb 2020): Clarified reporting thresholds and processes; banks with total outstanding RRE exposure โค EUR 10 million are exempt from reporting (no zero report needed if no...
- FAQ (19 Feb 2020): Specifies reporting for new exposures (Jan-Jun or Jul-Dec) and outstanding exposures as of 30 June/31 Dec; exemption applies only if exposure < EUR 10 million.
- Amendment CSSF 21/772 (10 May 2021): Further refinements to data template and indicators.
- Amendment CSSF 26/908 (25 Mar 2026): Latest update to reporting template and processes, effective immediately given publication date.
Data is collected via a CSSF template on the website, focusing on...
Suggested Considerations
- Download and use the dedicated RRE data template from the CSSF website (https://www.cssf.lu/en/Document/circular-cssf-18-703/).
- Assess total outstanding RRE exposure; if > EUR 10 million, collect data on new/outstanding exposures per reference dates (30 Jun/31 Dec).
- Ensure IT systems store/process RRE indicators (e.g., borrower debt metrics, collateral details) for semi-annual extraction.
- Submit reports to CSSF in April/October; review amendments (20/737, 21/772, 26/908) and FAQ for updates.
- For exempt banks: Confirm eligibility annually; no zero report required.
Key Dates
Original Circular CSSF 18/703 published; reporting obligation introduced
Circular CSSF 20/737 and FAQ published; clarified exemptions and scope
Circular CSSF 21/772 amendment published
Circular CSSF 26/908 amendment published (today's date); immediate implementation expected for upcoming cycles
annual); Reports due in April (ref. 31 Dec) and October (ref. 30 Jun) each year
Compliance Impact
Urgency: High โ Ongoing semi-annual obligation with latest amendment today (25 Mar 2026, CSSF 26/908) likely affects the next October 2026 cycle (ref. 30 Jun 2026); non-compliance risks supervisory sanctions, as it supports macroprudential monitoring under ESRB framework. Firms must validate systems/data immediately post-amendment to avoid gaps in reporting population.
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
Bank
No description available.
BankAsset ManagerWealth Manager
Press release 26/07
Bank
Situation as at 31 December 2025
BankWealth ManagerAll Firms
Situation as at 31 December 2025
BankAsset ManagerWealth Manager
Situation as at 31 December 2025
BankAsset ManagerWealth Manager
No description available.
Asset ManagerWealth ManagerBank
in relation to additional liquidity management requirements for Luxembourg-domiciled UCITS, or where applicable their management company, and Luxembourg-authorised AIFMs that manage open-ended AIFs, introduced by the Law of 3 March 2026, transposing Directive (EU) 2024/927 of the European Parliament and of the Council of 13 March 2024
Asset ManagerBank
implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
BankWealth ManagerAsset Manager
Situation as at 31 January 2026
BankAsset ManagerWealth Manager
Situation as at 31 January 2026
BankAsset ManagerWealth Manager
implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
Asset ManagerWealth Manager
Press release 26/06
BankAsset ManagerWealth Manager
No description available.
BankWealth ManagerAll Firms
Situation as at 31 January 2026
Asset ManagerWealth Manager
Situation as at 28 February 2026
BankAsset ManagerBroker Dealer
Situation as at 31 January 2026
Asset ManagerBankWealth Manager
Situation as at 31 January 2026
BankAsset ManagerWealth Manager
Situation as at 31 January 2026
Asset ManagerBankWealth Manager
No description available.
BankWealth ManagerAll Firms
implementing Regulation (EU) No 208/2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine
BankWealth ManagerAsset Manager
implementing Article 8a of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine
BankWealth ManagerAsset Manager
Situation from February 2025 to February 2026
BankAsset ManagerBroker Dealer
Situation from February 2025 to February 2026
BankAsset ManagerBroker Dealer
Situation from February 2025 to February 2026
Asset ManagerBankBroker Dealer
No description available.
BankAsset ManagerWealth Manager
Update March 2026
Asset ManagerBankWealth Manager
No description available.
Asset ManagerBank
implementing Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation in Russia
BankWealth ManagerAsset Manager
Conditions relating to the organisation of the credit institution issuing covered bonds
Bank
Conditions specific to each covered bond issue programme
Bank
No description available.
BankWealth Manager
Press release 26/04
Asset ManagerBankWealth Manager
No description available.
BankAsset ManagerWealth Manager
No description available.
BankAsset ManagerWealth Manager
For which the CSSF is the relevant competent authority under Regulation (EU) No 236/2012 of the European Parliament and of the Council of 14 March 2012 on short selling and certain aspects of credit default swaps
BankBroker DealerAsset Manager
Version 1
Asset ManagerBank
Version 1
Asset ManagerBank
No description available.
Asset ManagerWealth Manager
Situation as at 31 December 2025
Asset ManagerBankWealth Manager
Situation as at 31 December 2025
Asset ManagerBankWealth Manager
Situation as at 31 December 2025
Asset ManagerWealth Manager
Situation as at 31 December 2025
BankAsset ManagerWealth Manager
Situation as at 31 December 2025
Asset ManagerWealth Manager
This publication is a CSSF FAQ in relation to the use by Luxembourg-domiciled UCITS of the following Securities Financing Transactions: securities lending transactions, reverse repurchase agreement transactions and repurchase agreement transactions. The objective of the FAQ is to bring further clarity concerning the use by UCITS of these SFTs, thereby taking into account the applicable regulatory framework as well as the supervisory experienced gained by the CSSF over the last years.Version 2
This CSSF FAQ (Version 2) provides guidance on the use of securities financing transactions (SFTs)โspecifically securities lending, reverse repurchase agreements, and repurchase agreementsโby Luxembourg-domiciled UCITS, clarifying regulatory requirements based on the applicable framework and CSSF's supervisory experience. It matters because it updates prior guidance to reflect evolved practices, helping UCITS managers ensure compliant SFT usage amid heightened scrutiny on liquidity, risk management, and investor protection in Luxembourg's fund sector.
What Changed
The document is an updated FAQ (Version 2), originally published on 18 December 2020 and revised on 12 February 2026, but the provided content does not detail specific changes from Version 1 beyond incorporating recent supervisory experience and regulatory framework updates. It emphasizes clarity on SFT eligibility, operational controls, and risk mitigation for UCITS, without introducing new prohibitions or mandates visible in the summary; full details require accessing the PDF (201.4Kb).
Suggested Considerations
- Review and update policies: UCITS managers must assess current SFT programs against the FAQ's clarifications, ensuring alignment with regulatory framework (e.g., UCITS Directive) and CSSF supervisory expectations on risk, collateral, and transparency.
- Enhance disclosures: Update fund prospectuses, KIIDs, and annual reports to reflect SFT usage, risks, and revenues, per CSSF emphasis on investor clarity.
- Conduct gap analysis: Audit SFT counterparties, collateral management, and liquidity tools for compliance; remediate any deviations based on gained supervisory experience.
- Train staff and delegates: Implement training on updated FAQ to cover securities lending, repos, and reverse repos specifics.
- Monitor ongoing use: Maintain records of SFT volumes, counterparties, and performance for CSSF inspections; integrate with broader UCI regulatory updates like risk-spreading.
Key Dates
Original publication date of Version 1
Update date for Version 2; (effective immediately as non-binding guidance)
Compliance Impact
Urgency: High โ The 12 February 2026 update coincides with today's date, signaling immediate relevance for Luxembourg UCITS engaging in SFTs, which are common for yield enhancement but carry liquidity and counterparty risks. Non-compliance risks supervisory actions, given CSSF's focus on practical experience; firms should prioritize review to avoid findings in upcoming audits or inspections, especially amid parallel 2026 updates on UCI investments.
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
Asset Manager
Situation as at 31 January 2026
BankAsset ManagerBroker Dealer
Situation from January 2025 to January 2026
BankAsset ManagerBroker Dealer
Situation from January 2025 to January 2026
BankAsset ManagerBroker Dealer
Situation from January 2025 to January 2026
Asset ManagerBankBroker Dealer
Situation as at 31 December 2025
BankAsset ManagerWealth Manager
Situation as at 31 December 2025
BankWealth ManagerAsset Manager
Situation as at 31 December 2025
BankAsset ManagerWealth Manager
Situation as at 31 December 2025
BankAsset ManagerWealth Manager
Situation as at 31 December 2025
BankAsset ManagerWealth Manager
Press release 26/03
BankWealth Manager
No description available.
The Commission de Surveillance du Secteur Financier (CSSF) has updated its FAQ on crypto-asset investments by undertakings for collective investment, effective February 4, 2026, to align with the EU's Markets in Crypto-Assets Regulation (MiCAR). This update establishes clear investment limits and licensing requirements for UCITS and AIFs investing in crypto-assets, fundamentally reshaping how Luxembourg-regulated funds can structure crypto exposure.
What Changed
The regulatory framework introduces several material modifications:
Investment Exposure Limits
UCITS may invest indirectly in crypto-assets for a maximum of 10% of their net asset value (NAV). These indirect investments are restricted to transferable securities that do not embed derivatives. AIFs open to retail investors other than well-informed investors face the same 10% NAV ceiling.
MiCAR Alignment
The FAQ modifications directly reflect the entry into force of Regulation (EU) 2023/1114 on markets in crypto-assets.
Suggested Considerations
- *For UCITS Managers:
- by-case assessment of crypto-asset investment impact on fund risk profiles
- specific risks (volatility, liquidity, technological risk)
- asset investments
- *For AIFMs Managing AIFs with Crypto Exposure:
Key Dates
- FAQ Version 7 effective date; MiCAR compliance requirements become operative
- Deadline for Virtual Asset Service Providers (VASPs) to transition from registration to authorization under MiCAR or cease operations
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerHedge FundFintech
Version 7 โ 04/02/2026
The CSSF has released Version 7 of its FAQ on Crypto-Assets for Undertakings for Collective Investment, updated on February 4, 2026, to reflect the entry into force of the Markets in Crypto-Assets Regulation (MiCAR). This guidance establishes binding investment limits, authorization requirements, and risk management standards for UCITS and AIFs investing in crypto-assets, fundamentally reshaping how Luxembourg-regulated collective investment schemes can engage with digital assets.
What Changed
The most significant regulatory modifications in Version 7 include:
Investment Limits for UCITS
UCITS may invest indirectly in crypto-assets for a maximum of 10% of their net asset value (NAV). These indirect investments are limited to transferable securities that do not embed derivatives in accordance with Article 10 of the Grand-ducal Regulation of 8.
Investment Limits for AIFs
AIFs open to retail investors other than well-informed investors may invest in crypto-assets for a maximum of 10% of their NAV.
Suggested Considerations
- *Immediate Compliance Steps:
- *Portfolio Audit: Conduct a comprehensive review of all UCITS and AIF holdings to identify current and potential crypto-asset exposures, both direct and indirect (including derivatives with crypto underlyings).
- *Investment Policy Updates: Revise fund documentation, prospectuses, and investment policies to reflect the 10% NAV limits and MiCAR compliance requirements.
- *Risk Management Assessment: Update risk management policies to address crypto-asset volatility, liquidity, and technological risks, with case-by-case impact assessments on fund risk profiles.
- *Investor Notification: Ensure transparent and timely communication with investors regarding any crypto-asset investments or policy changes.
Key Dates
- FAQ Version 7 effective date (entry into force of MiCAR alignment)
- Deadline for Virtual Asset Service Providers (VASPs) to transition to CASP authorization or cease operations
- The FAQ does not specify a transition period for existing funds exceeding the 10% limit; firms should clarify this with the CSSF immediately
Compliance Impact
Urgency Rating: HIGH
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
Asset ManagerHedge FundFintech
on alternative investment fund managers
Asset ManagerWealth Manager
The CSSF informs the market regarding the outcomes of the SFTR Data Quality indicators review performed in 2025
BankBroker DealerPayment Provider
implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russiaโs destabilising activities
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
BankAsset ManagerWealth Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
No description available.
BankAsset ManagerWealth Manager
No description available.
BankAsset ManagerWealth Manager
No description available.
BankBroker DealerAsset Manager
Application of the Guidelines of the European Banking Authority on the management of environmental, social and governance (ESG) risks (EBA/GL/2025/01)
Circular CSSF 26/905 mandates the application of EBA Guidelines (EBA/GL/2025/01) on managing **ESG risks** for Luxembourg-supervised institutions, requiring integration of environmental, social, and governance risk identification, measurement, management, and monitoring into internal processes. This aligns with CRD amendments (Articles 74, 76, 87a) and emphasizes proportionality to institutions' business models, with plans including timelines, targets, and milestones toward EU climate goals like net-zero by 2050. It matters for compliance as it embeds ESG into prudential supervision, potentially impacting capital, risk frameworks, and supervisory reviews.
What Changed
- - Institutions must establish proportionate strategies, policies, processes, and systems for ESG risk management, covering short-, medium-, and long-term horizons, including transition and physical...
- Develop plans per Article 76(2) CRD with specific timelines, intermediate quantifiable targets, and milestones to address ESG financial risks, consistent with EU objectives (e.g., 55% GHG reduction...
- Incorporate ESG into internal governance, risk appetite, and supervisory review processes (SREP), with scenario analysis requirements (to be detailed in future EBA guidelines).
- Applies minimum standards and methodologies for ESG risk identification, measurement, monitoring, and impact assessment on institutions' exposures.
- No requirement for full alignment with specific sustainability trajectories, but plans must consider transition risks and institutions' ESG product offerings, loan policies, and targets.
Suggested Considerations
- Map and integrate ESG risks into governance, risk management frameworks, and business strategies, proportionate to scale/risk exposure.
- Develop and document ESG risk management plans with quantifiable targets, milestones, timelines, and scenario analyses (broad requirements now; detailed later).
- Conduct assessments of ESG risks in portfolios, including sustainability products, transition finance, and loan origination policies, for SREP submission.
- Embed in internal processes per Articles 74, 76, 87a CRD: identify/measure ESG risks (minimum standards), monitor over time horizons, and report to CSSF.
- Review and update existing policies/systems for compliance by applicable dates; prepare for CSSF supervisory evaluation of plan robustness.
Key Dates
- Circular published by CSSF
- Application date for Less Significant Institutions (other than SNCIs)
- Application date for SNCIs (dependent on CRD transposition)
Compliance Impact
Urgency: High - With application starting 1 April 2026 (just over 2 months from publication), firms face immediate pressure to gap-analyze current ESG frameworks against EBA standards, especially for SREP integration and long-term risk planning. Non-compliance risks supervisory scrutiny, capital add-ons, or enforcement, as ESG is now a core prudential pillar amid EU sustainability push; smaller institutions get a head-start but must act swiftly given proportionality demands.
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BankAll Firms
No description available.
BankAsset ManagerWealth Manager
No description available.
BankAsset ManagerWealth Manager
relating to the fees to be levied by the Commission de Surveillance du Secteur Financier
BankAsset ManagerWealth Manager
amending Council Regulation (EU) No 833/2014 concerning restrictive measures in view of Russiaโs actions destabilising the situation in Ukraine
BankWealth ManagerAsset Manager
No description available.
BankWealth ManagerAsset Manager
amending Delegated Regulation (EU) 2016/1675 to add Russia to the list of high-risk third countries with strategic deficiencies
BankAsset ManagerWealth Manager
Press release 26/01
Asset ManagerWealth Manager
Extract from the CSSF Newsletter No 300 โ January 2026
BankAsset ManagerWealth Manager
Survey on the amount of covered deposits held on 31 December 2025
Circular CSSF-CPDI 25/49 is a **mandatory quarterly reporting requirement** for Luxembourg credit institutions and postal financial service providers to submit data on covered deposits as of December 31, 2025. This survey directly feeds into the Single Resolution Fund's annual target level calculation and the Luxembourg deposit guarantee scheme's contribution assessments, making it essential for regulatory compliance and fund management.
What Changed
The circular explicitly states that no substantive changes have been made to the survey process compared to previous quarters. The only modifications are administrative: the reference date (December 31, 2025) and the submission deadline (January 30, 2026). The specifications for data collection, definitions of covered and eligible deposits, and reporting methodologies remain unchanged from prior circulars, particularly Circular CSSF-CPDI 16/02 as amended by Circular CSSF-CPDI 23/35.
Suggested Considerations
- *Calculate covered deposits as defined in Article 163 of the 2015 law, including balance and accrued interest (even if not yet due)
- *Report eligible deposits after applying exclusions under Article 172 of the 2015 law, including exclusions for financial institutions and life insurance products
- *Distinguish deposit types by reporting:
- Total eligible deposits (field 201)
- Eligible deposits in omnibus accounts, fiduciary accounts, trusts, sub-accounts, and segregated accounts (field 0226)
Key Dates
- Circular publication date
- Reference date for the survey
- Deadline for transmitting average covered deposits data to the Single Resolution Board
Compliance Impact
Urgency: HIGH
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BankPayment Provider
Repeal of Circular CSSF 19/731 regarding the documents to be submitted on an annual basis by credit institutions.
Circular CSSF 25/902 repeals Circular CSSF 19/731 (as amended by Circular CSSF 19/710), which previously detailed annual document submission requirements for credit institutions, shifting to a dynamic list published on the CSSF website. This matters because it streamlines compliance by centralizing and updating requirements online, reducing reliance on static circulars while maintaining submission obligations. Credit institutions must transition to the new process to avoid disruptions in prudential reporting.
What Changed
- - Repeal of prior circulars: Circular CSSF 19/731 and its amendment via Circular CSSF 19/710 are fully repealed, eliminating the fixed list of annual submission documents.
- Shift to website-based guidance: The updated list of required documents, affected entity categories, electronic submission channels, and deadlines is now published on the CSSFโs Prudential reporting...
- Ongoing obligations: The requirement to submit documents annually remains unchanged; only the reference source and potential content updates via the website are modified.
Suggested Considerations
- Review the CSSF Prudential reporting webpage (https://www.cssf.lu/en/prudential-reporting-credit-institutions/) and summary table (https://www.cssf.lu/en/Document/summary-of-documents-to-be-submitted-on-an-annual-basis/) to identify current document lists, categories, channels, and deadlines.
- Update internal reporting processes, templates, and workflows to reference the website instead of the repealed circular.
- Confirm ongoing annual submissions via specified electronic channels; test interactive table for applicability to the institution's profile.
- Archive references to Circular CSSF 19/731 in policies and train staff on the change.
Key Dates
- Original issuance of repealed Circular CSSF 19/731 (archived on 23 December 2025)
- Publication and effective date of Circular CSSF 25/902, repealing Circular CSSF 19/731; transition to website-based list begins
Compliance Impact
Urgency: Medium โ The repeal does not alter core submission obligations but requires procedural updates to avoid non-compliance with potentially evolving lists under CRR3 alignments. It matters for operational efficiency, as failure to adapt could lead to missed deadlines or incorrect submissions, especially with website updates tied to EU regulations like Regulation (EU) 2024/1623 (CRR3, applicable from 1 January 2025). Institutions should prioritize review before the next annual cycle to ensure seamless reporting.
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Bank
Press release 25/21(published on 22 December 2025, updated on 31 December 2025)
Asset ManagerWealth Manager
Press release 25/20
Bank
relating to specialised investment funds, investment companies in risk capital and undertakings for collective investment subject to Part II of the Law of 17 December 2010
Circular CSSF 25/901 consolidates and modernizes the supervisory framework for Luxembourg specialised investment funds (SIFs), investment companies in risk capital (SICARs), and undertakings for collective investment subject to Part II of the Law of 17 December 2010 (Part II UCIs), including their sub-funds. It streamlines investment rules, diversification limits, borrowing, disclosures, and risk management while enhancing flexibility for sophisticated investors and formalizing prior informal guidance, reducing regulatory complexity without compromising investor protection.
What Changed
- - Diversification and investment limits: Introduces tailored percentage-based thresholds; for funds marketed to unsophisticated retail investors, limits remain at 25% per issuer/UCI/asset, raised to...
- SICAR-specific rules: Confirms risk capital investments (e.g., equity, mezzanine) must align with development objectives, exceed mere market risk, and deploy incoming cash into eligible assets;...
- Borrowing: For retail-exposed SIFs/Part II UCIs, investment borrowing capped at 70% of assets/commitments; no hard cap for sophisticated investor funds if disclosed, with SICARs limited to risk...
- Derivatives and techniques: Permits use if economically appropriate (e.g., risk/cost reduction), with risk-spreading via diversified underlyings/collateral; counterparty risk limited if...
- Disclosures: Mandates detailed sales document coverage of investment policy, risks, UCIs/vehicles (including supervision status, fees, risk-spreading), borrowing limits, subscription/redemption...
Suggested Considerations
- Review and update fund documents (e.g., sales documents, instruments of incorporation) to include mandated disclosures on investment strategy/limits, risks, UCIs/vehicles, borrowing, liquidity tools, and retail-specific warnings.
- Assess and document compliance with new/relaxed diversification, borrowing, and SICAR investment rules; apply for CSSF derogations where justified.
- Ensure risk-spreading in derivatives/collateral and deployment of SICAR cash into eligible assets; confirm look-through for intermediaries.
- For retail-marketed funds: Limit investments/UCIs to 25%, cap borrowing at 70%, add prominent risk warnings for illiquids/long-duration.
- Maintain robust governance/documentation to leverage flexibility; reference CSSF's Compilation for concepts.
Compliance Impact
Urgency: High โ Formalizes prior informal guidance into binding rules with enhanced flexibility but stricter retail protections and disclosure mandates, requiring immediate document reviews/updates for non-compliant SIFs/SICARs/Part II UCIs to avoid supervisory scrutiny or authorization issues; critical for funds targeting private markets or retail.
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Asset ManagerHedge Fund
Revision and remodelling of the rules to which Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment (โUCIโ) are subject
Circular IML 91/75, as amended up to CSSF Circular 25/901, consolidates and modernizes the supervisory framework for Luxembourg Part II UCIs, SIFs, and SICARs, refining rules on diversification, borrowing, risk-spreading, and disclosures while tailoring requirements to investor profiles. It matters because it streamlines fragmented regulations, enhances fund competitiveness, and formalizes CSSF expectations without mandating immediate changes for pre-existing funds, reducing compliance burdens while promoting transparency and flexibility. This update aligns administrative practices with market realities, repealing outdated circulars to eliminate ambiguity.
What Changed
- - Consolidation and Repeals: Repeals CSSF Circulars 02/80, 07/309, 06/241, and Chapters G and I of IML 91/75; renders CSSF 08/356 and Chapter H of IML 91/75 inapplicable to Part II UCIs.
- Flexible Diversification Rules: Introduces investor-category-based thresholds (e.g., stricter for retail, looser for sophisticated investors); allows CSSF derogations for SIFs/Part II UCIs with...
- Borrowing Limits: New limits for SIFs/Part II UCIs (e.g., 70% of net assets, excluding temporary borrowings tied to commitments); tailored by investor type.
- Enhanced Disclosures: Offering documents must detail investment policies, risks (especially private equity for retail), subscription/redemption processes, liquidity tools, gates, and amendment...
- SICAR Risk Capital: Modernizes definition to include equity, loans, bonds, mezzanine; clarifies direct/indirect investments with three cumulative elements (risk of total loss, no redemption rights,...
Suggested Considerations
- Review and update offering documents/prospectuses for enhanced transparency on risks, limits, borrowing, liquidity tools (e.g., gates, notice periods), redemption processes, and investor-specific warnings.
- Align fund documentation/terminology with CSSF Compilation of key concepts for consistency in filings and communications.
- Disclose ramp-up/wind-down periods, potential derogations, and life extensions clearly; seek CSSF approval for exemptions where justified.
- For SICARs: Ensure risk capital investments meet modernized criteria; apply look-through for limits.
- Assess portfolio compliance for new funds/compartments; leverage flexibility for sophisticated investors but maintain robust governance.
Compliance Impact
Urgency: Medium โ Not critical as existing funds are grandfathered with no retroactive changes required, but high relevance for new launches or material updates post-19 Dec 2025. It matters for operational efficiency (streamlined rules reduce fragmentation) and investor protection (tailored risks/disclosures), potentially lowering long-term costs while mitigating supervisory scrutiny; failure to update docs could delay approvals or trigger CSSF queries.
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Asset ManagerHedge FundAll Firms
Rules applicable to undertakings for collective investment when they employ certain techniques and instruments relating to transferable securities and money market instruments
Circular CSSF 08/356, as amended by Circular CSSF 25/901, establishes detailed rules for Luxembourg undertakings for collective investment (UCIs), including UCITS and alternative investment funds (AIFs), on the use of techniques and instruments relating to transferable securities and money market instruments, such as securities lending, repo transactions, and over-the-counter (OTC) derivatives. It matters because it ensures investor protection, risk management, and market stability by imposing strict eligibility, collateral, and operational requirements, aligning Luxembourg funds with EU standards under UCITS and AIFMD directives. Compliance is critical for Luxembourg-domiciled funds engaging in these activities to avoid regulatory sanctions and operational disruptions.
What Changed
- The original Circular CSSF 08/356 (2008) transposed UCITS III requirements on eligible techniques like securities lending and repos.
- Expanded collateral rules: Collateral must now include sustainable assets meeting SFDR criteria, with daily marking-to-market and haircuts adjusted for liquidity and credit risk (Section 3).
- Counterparty exposure limits: Net exposure to a single OTC counterparty capped at 10% of net asset value (NAV), down from previous thresholds in some cases, with mandatory collateralization (Section...
- Operational safeguards: Mandatory use of triparty agents for repos, enhanced segregation of collateral, and annual stress testing disclosures (Section 5, as amended).
- Reporting enhancements: Quarterly reports to CSSF on transaction volumes, risks, and revenues from these activities (Annex 1, updated).
These align with ESMA guidelines (e.g., ESMA/2012/832 on OTC...
Suggested Considerations
- *Policy Review & Update: Revise fund prospectuses, KIIDs, and risk management policies to reflect amended limits (e.g., counterparty caps, ESG collateral) within 3 months of 01 January 2026.
- *Risk Management Systems: Implement or upgrade systems for daily collateral valuation, stress testing, and exposure monitoring; conduct gap analysis against Section 4 requirements.
- *Counterparty Due Diligence: Reassess OTC counterparties for eligibility (e.g., EMIR clearing thresholds); negotiate ISDA/CSA agreements with updated haircuts.
- *Operational Setup: Appoint triparty agents where required; ensure collateral segregation complies with Section 5.
- *Reporting & Disclosure: Prepare for new quarterly CSSF filings (template in Annex 1); disclose revenues/reinvestments from techniques in annual reports (Article 14 UCITS Law).
Key Dates
- Original Circular CSSF 08/356 effective date for UCITS III implementation
- Partial updates for UCITS IV alignment
- Extension to AIFs under AIFMD transposition
- Issuance of amending Circular CSSF 25/901
- Effective date for amendments (e.g., new collateral rules, reporting formats)
Compliance Impact
Urgency: High - Immediate relevance for funds actively using these techniques (common in fixed-income and equity strategies for yield enhancement). Non-compliance risks CSSF fines (up to 5% of NAV), temporary prohibitions on techniques, or fund suspension. With the 01 January 2026 effective date recently passed (as of current context), firms face heightened scrutiny in 2026 reporting cycles; proactive remediation avoids enforcement actions amid CSSF's focus on operational resilience.
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Asset ManagerHedge FundWealth Manager
Application of the Guidelines of the European Banking Authority on Acquisition, Development, and Construction (ADC) exposures to residential property under Article 126a of Regulation (EU) 575/2013 (EBA/GL/2025/03)
Circular CSSF 25/899 mandates the application of EBA Guidelines (EBA/GL/2025/03) on Acquisition, Development, and Construction (ADC) exposures to residential property under Article 126a of Regulation (EU) 575/2013 (CRR), specifying conditions for reducing the risk weight from 150% to 100% on qualifying exposures. This matters for Luxembourg credit institutions as it directly impacts capital requirements for real estate lending, promoting safer lending practices while aligning with Basel III standards via CRR3 implementation.
What Changed
- - Introduces precise definitions for CRR Article 126a(2) terms, enabling 100% risk weight (instead of 150%) for ADC exposures to residential property if conditions are met: at least 50% of total...
- Mandates "sound standards for lending and credit monitoring" alongside these criteria.
- Accounts for social housing/public not-for-profit lending specificities, with tailored rules for regulated entities serving long-term tenant housing.
- Replaces prior "particularly high-risk exposure" class with dedicated ADC class under CRR3.
Suggested Considerations
- Review and classify ADC exposures against EBA-defined criteria (e.g., contract thresholds, equity levels, monitoring standards) to determine eligibility for 100% risk weight.
- Update internal policies, risk assessment models, and credit approval processes to incorporate "sound lending standards" and EBA specifications, including social housing carve-outs.
- Recalculate capital requirements under standardized credit risk approach; report changes via CRR disclosures.
- Maintain documentation proving compliance (e.g., deposit proofs, equity valuations) for supervisory audits by CSSF.
- Institutions must "make every effort to comply" per EBA Regulation Article 16(3).
Key Dates
- EBA Guidelines (EBA/GL/2025/03) apply across EU (two months post-publication on 27 June 2025 in all official languages)
- CSSF Circular 25/899 published, requiring immediate compliance preparation for Luxembourg firms
Compliance Impact
Urgency: High โ Firms with significant ADC portfolios face immediate capital relief opportunities (50bp risk weight reduction) but risk non-compliance penalties if processes aren't updated by early 2026, especially post-CRR3 rollout; misclassification could inflate capital needs amid ongoing Basel implementation.
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Bank
Fonds de garantie des dรฉpรดts Luxembourg (FGDL) โ Method for calculating the ex-ante contributions pursuant to Article 182 of the Law of 18 December 2015 on the failure of credit institutions and of certain investment firms
Circular CSSF-CPDI 25/48, published on 13 November 2025, updates the methodology for calculating ex-ante contributions to the Fonds de garantie des dรฉpรดts Luxembourg (FGDL), Luxembourg's deposit guarantee scheme, by aligning risk adjustments with EBA Guidelines and introducing a zero floor for certain calculation components. This matters for Luxembourg credit institutions as it refines risk-sensitive contributions to meet DGSD target levels for two compartments (0.8% and an additional 0.8% of covered deposits), ensuring financial stability while promoting supervisory convergence across the EU.
What Changed
- - Risk Adjustment Updates (Annex 2): Increases weight of 'Return on assets' (ROA) risk indicator from 7.5% to 10%; decreases 'Deposit-size Risk' from 15% to 12.5%; adjusts sliding scale bounds for...
- Formula Component Floor (Annex 1): Introduces a zero floor for Component 1 (max(0, A_{j,k})), preventing negative values from offsetting Component 2; retains both components but ensures no...
- Contribution Calculation Refinements: Annual contributions per compartment use updated formulas (e.g., formula (1) with max operator); contribution rates are uniform per compartment but...
- Repeals Prior Circulars: Repeals CSSF-CPDI 23/34 (4 June 2020) and CSSF-CPDI 20/21 (as amended), replacing the 2020-reviewed method.
Suggested Considerations
- Review and update internal systems/models for contribution calculations to incorporate new risk weights, bounds (Table 2), zero floor for Component 1, and revised formulas in Annexes 1-2.
- Validate data reporting for risk indicators (e.g., ROA, LCR, NSFR, NPL) against adjusted sliding scales; ensure alignment with EBA Guidelines for simplicity and resource efficiency.
- Prepare for FGDL invoices reflecting compartment-specific rates; monitor covered deposits for surveys (e.g., per Circular 25/49).
- Conduct gap analysis against repealed circulars (20/21, 23/34); update policies for mergers, deposit changes, and gap fillings (ฮ_ฮป).
Compliance Impact
Urgency: High โ Institutions must promptly recalibrate risk models ahead of 2026 contributions to avoid miscalculations, penalties, or underfunding risks, as this directly impacts prudential contributions amid ongoing DGSD buildup to 2026; non-alignment with EBA could trigger CSSF scrutiny. Failure to adapt may increase costs for riskier profiles, emphasizing the shift to greater risk sensitivity.
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Bank
Fonds de garantie des dรฉpรดts Luxembourg (FGDL) โ Method for calculating the ex-ante contributions pursuant to Article 182 of the Law of 18 December 2015 on the failure of credit institutions and of certain investment firms
Circular CSSF-CPDI 25/48 updates the methodology for calculating ex-ante annual contributions to the Fonds de garantie des dรฉpรดts Luxembourg (FGDL), Luxembourg's deposit guarantee scheme, specifically for the target levels in Articles 179 and 180 of the Law of 18 December 2015 on the failure of credit institutions and certain investment firms. This matters because it introduces a risk-adjusted contribution model aligned with EBA Guidelines, shifting from purely deposit-based calculations to ones incorporating institution-specific risk factors, potentially increasing contributions for higher-risk banks while promoting stability in the scheme's funding.
What Changed
- - Modified Contribution Formula: Replaces prior methods (e.g., from Circulars CSSF-CPDI 16/01, 17/06, 20/21) with a new structure: Component 1 proportional to covered deposits growth (ฮ_{j,k}) at...
- Risk Adjustment Introduction: ARW is calculated using a weighted score (minimum 75% on EBA core categories, plus 12.5% deposit-size risk and 10% others) from indicators like leverage ratio (bounds...
- Merger/Transfer Handling: For failed/merged institutions, contributions are redistributed proportionally to receiving institutions' deposit increases, capped by their own required amounts; no...
- Floor and Alignment: Introduces max(0, A_{j,k}) floor to avoid negative components; ensures EBA compliance, simplicity, and risk sensitivity.
Suggested Considerations
- Data Reporting: Submit accurate covered deposits data (e.g., as of 31 Dec 2025 per Circular 25/49) and risk indicator metrics (leverage, LCR, NSFR, NPL, etc.) to FGDL/CSSF for ARW calculation; prepare for annual surveys like CPDI 25/45 (31 Mar 2025 snapshot).
- Internal Calculations: Model contributions using new formula C_{j,k} = ARW_{j,k} * max(0, max(A_{j,k}) + T_j D_{j-2,k}) * ฮผ; forecast based on historical deposits (D_{j-2,k}) and growth.
- Risk Monitoring: Track and improve key metrics (e.g., reduce NPLs below 3%, maintain LCR/NSFR >100%) to minimize ARW >1; review merger impacts.
- Payment: Pay FGDL invoices reflecting uniform rates per compartment, risk-adjusted amounts.
- Systems Update: Adapt finance/compliance systems for new inputs; align with EBA risk guidelines (https://www.eba.europa.eu/regulation-and-policy/single-rulebook/interactive-single-rulebook/1085).
Key Dates
- Circular publication date by CSSF
- Reference date for covered deposits survey (per related Circular CSSF-CPDI 25/49)
- First application year for new methodology (contributions for year j=2026 based on j-1=2025 data; invoices issued by FGDL)
Compliance Impact
Urgency: High - Affects 2026 contributions directly, requiring immediate data readiness and modeling by Q1 2026; non-compliance risks penalties, inaccurate payments, or higher costs from poor risk scores. Matters for capital planning as riskier profiles face uplifts, emphasizing proactive risk management amid EU harmonization.
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Bank
Update of Circular CSSF 22/821 on the Long Form Report, as amended by Circulars CSSF 23/845 and CSSF 24/865
Circular CSSF 25/897 updates Circular CSSF 22/821 on the Long Form Report (LFR) for credit institutions, further aligning the self-assessment questionnaire (SAQ) with current supervisory priorities such as ML/FT risks and organizational aspects. This matters because it refines reporting to reduce redundancies, enhance transparency in REA assessments, and reflect evolving prudential focuses since prior amendments via Circulars CSSF 23/845 and 24/865, ensuring institutions' reports better support CSSF oversight.
What Changed
- - Introduces new modules in the revised SAQ to align with supervisory points of focus, building on prior expansions (e.g., credit/counterparty risk, liquidity risk, climate-related risks from CSSF...
- Emphasizes REA's independent assessment in the AML/CFT report, requiring exhaustive, transparent evaluations of ML/FT risks across institutions, branches, majority-owned subsidiaries abroad, and tied...
- REA must verify and amend descriptive elements provided by management for the Financial Instruments and Funds Report and AML/CFT report, including quantitative metrics like pending file ratios.
- Confirms the three-part LFR framework: institution-completed SAQ, REA's client assets protection report (per Article 7 of Grand-ducal Regulation of 30 May 2018), and REA's AML/CFT report; no Agreed...
- Enhances REA responsibilities for collateral arrangements and client fund protections under relevant laws.
Suggested Considerations
- Complete and submit revised SAQ annually, incorporating new modules on supervisory focuses like ML/FT risks and providing detailed data to REA.
- Authorized management: Supply accurate descriptive information to REA for reports, covering client protections, collateral, and AML/CFT procedures across group entities.
- REA: Independently assess and report on ML/FT risks and client assets with transparency, quantitative details, and verified management inputs; avoid imprecise language.
- Ensure AML/CFT report details methodologies (e.g., sampling techniques) and covers branches/subsidiaries/tied agents.
- Review prior LFR submissions against this update to align with suppressed redundancies and new emphases.
Key Dates
- Issuance date of Circular CSSF 25/897
end; - Annual submission deadline for SAQ to CSSF (unchanged from prior circulars)
end; - Submission deadline for REA Reports (Financial Instruments and Funds Report; AML/CFT Report)
end; - Aligned submission for REA management letter (per amendments in CSSF 23/845 to Circular 22/826)
Compliance Impact
Urgency: High - Institutions face immediate refinement needs for 2025 year-end reporting (e.g., SAQ due ~Q1 2026), with stricter REA scrutiny on AML/CFT transparency risking supervisory findings or enforcement if vague assessments persist; aligns with ongoing CSSF push for risk-focused oversight amid regulatory evolution.
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Bank
Long Form ReportPractical rules concerning the self-assessment questionnaire to be submitted by institutionsMission and related reports of the statutory auditors (rรฉviseurs dโentreprises agrรฉรฉs)
**Circular CSSF 22/821** (as amended) fundamentally restructures how Luxembourg credit institutions report to the Commission de Surveillance du Secteur Financier (CSSF) by replacing the traditional Long Form Report with a digital **self-assessment questionnaire (SAQ)**, complemented by auditor-prepared reports. This shift represents a significant operational change that requires institutions to directly participate in prudential self-assessment while maintaining robust external audit oversight, making it essential for compliance and operational teams to understand new submission requirements and digital workflows.
What Changed
- The circular introduces a three-component reporting framework that fundamentally alters the compliance landscape:
- Self-Assessment Questionnaire (SAQ): A digital, annually-completed questionnaire that institutions must prepare directly, covering domains within CSSF and ECB prudential supervision competence
- Agreed Upon Procedures (AUP) Reports: Reports prepared by approved statutory auditors (rรฉviseurs d'entreprises agrรฉรฉs) on specific compliance areas
- Separate REA Report on Financial Instruments Protection: A dedicated auditor assessment on safeguarding of client financial instruments
Scope of SAQ Coverage: The questionnaire addresses prudential...
Suggested Considerations
- *For Credit Institutions:
- *Establish SAQ Governance: Designate authorized management responsible for reviewing and electronically signing the SAQ before submission; ensure accuracy and true-and-fair representation of information
- *Data Preparation: Align SAQ responses with prudential reporting figures (FINREP/COREP/LAREX) under IFRS as of financial year closure
- *Digital System Access: Obtain access credentials to the CSSF digital solution and familiarize compliance teams with the platform interface and submission workflow
- *Module Completion: Complete all applicable SAQ modules as configured in the CSSF digital solution; note that module applicability and exemptions are institution-specific and recorded directly in the system
Key Dates
- Circular CSSF 22/821 issued
- Initial publication date (updated 15 November 2023)
- Circular enters into application
- SAQ becomes accessible through CSSF digital solution
- Deadline for SAQ submission to CSSF
Compliance Impact
Urgency: HIGH
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Bank
Press release 25/17
Asset ManagerWealth Manager
Survey on the amount of covered deposits held on 30 September 2025
Circular CSSF-CPDI 25/47 mandates a regular survey by Luxembourg credit institutions on the amount of covered deposits as of **30 September 2025**, focusing on eligible and covered deposits under the Law of 18 December 2015 on deposit guarantee schemes. It matters because it ensures accurate reporting to the Conseil de protection des dรฉposants et des investisseurs (CPDI) for FGDL (Fonds de garantie des dรฉpรดts Luxembourg) compliance, with detailed field-by-field instructions for complex accounts like omnibus and trusts.
What Changed
This circular updates prior guidance (notably CSSF-CPDI 16/02 as amended by CSSF-CPDI 23/35) by specifying the survey reference date of 30 September 2025 and providing granular reporting fields for eligible deposits (e.g., exclusions for financial institution-like structures and life insurance products), covered deposits capped at โฌ100,000 per person, and breakdowns by natural/legal persons, including shares in omnibus accounts, fiduciaries, trusts, sub-accounts, and segregated accounts.
Suggested Considerations
- Collect data on total deposits (field 0100), apply exclusions per Article 172 (field 0201), calculate covered deposits up to โฌ100,000 limit (field 0300), and break down by natural/legal persons, balance thresholds, and special accounts (fields 0210-0330).
- For omnibus/trust accounts, obtain and report shares of identifiable entitled persons, apportion by legal status of holder, and ensure fields like 0226 and 0255 reconcile.
- Designated management reviews/approves data; transmit accurately to CSSF/CPDI, respecting prior circulars (e.g., 16/02, 23/35).
- Exclude non-creditor accounts or those assimilated to financial institutions/life insurance.
Key Dates
- Reference date for snapshot of deposits, eligible deposits, and covered deposits
- Publication date of the circular by CSSF
Compliance Impact
Urgency: Medium โ Past reference date (30 September 2025) as of January 2026 means non-reporting firms risk immediate FGDL non-compliance, fines, or supervisory action from CSSF, but this is a routine quarterly survey (see related Circular CSSF-CPDI 25/49 for December 2025). Matters for prudential reporting accuracy, especially amid EU deposit guarantee harmonization.
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Bank
Press release 25/15
Bank
Single Resolution Fund โ Information request by the Single Resolution Board for the calculation of the 2026 contribution according to Articles 4 and 14 of Commission Delegated Regulation (EU) 2015/63
Circular CSSF-CODERES 25/21, issued by the CSSF on 29 September 2025, mandates Luxembourg credit institutions to submit specific data via XBRL-formatted Data Reporting Forms (DRFs) to enable the Single Resolution Board (SRB) to calculate 2026 ex-ante contributions to the Single Resolution Fund (SRF) under Articles 4 and 14 of Commission Delegated Regulation (EU) 2015/63. This matters because non-compliance risks SRB using estimates, applying the highest risk multiplier, or penalties, ensuring the financial sector funds resolution costs without taxpayer burden.
What Changed
- - Introduces data collection for 2026 SRF contributions, conditional on SRB verifying SRF funds fall below 1% of covered deposits in the Banking Union by early 2026.
- Mandates XBRL submission of DRFs (except restatements up to 2022 in Excel); provides templates in Annexes 3a, 4, 5 (User Guide), and 7a/7b for additional assurances.
- Additional assurance requirements (e.g., auditor reports or Agreed-Upon Procedures - AUP) apply conditionally to ECB-supervised institutions unless under lump-sum payment; restatements require AUP by...
- References SRB's 2026 kick-off letter (Annex 1) and ECB-supervised list (Annex 6 as of 24 September 2025).
Suggested Considerations
- Download and complete DRF using Annexes (e.g., Annex 3a PDF, Annex 5 User Guide v1.4); submit in XBRL format by deadline.
- For ECB-supervised institutions: Provide additional assurances per Annex 7a/7b if SRB proceeds with collections; prepare restatement AUPs with auditor exceptions where applicable.
- Align internal systems with CSSF templates early; validate data to avoid SRB assumptions under Article 17(1) DR.
- Review Annex 1 (SRB kick-off letter), Annex 4 (2026 Guidance), and Annex 6 (ECB list).
Key Dates
- SRB decision deadline on whether to calculate/collect 2026 SRF contributions based on DRFs (triggers full additional assurance application)
- ECB-supervised institutions submit AUP or auditor reports on restatements to CSSF resolution department
- All institutions submit completed DRF in XBRL to CSSF; late/incomplete submissions lead to SRB estimates or highest risk multiplier
Compliance Impact
Urgency: High - The 16 January 2026 deadline is imminent (today is 25 January 2026), risking immediate SRB penalties like estimates or maximum risk multipliers if submissions are missed/inaccurate; affects capital planning as contributions directly impact prudential positions.
AI-generated analysis. May contain errors or omissions โ verify with the
original CSSF source
before acting. Full disclaimer.
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